STAKEHOLDER ENGAGEMENT IN FSC FOREST MANAGEMENT CERTIFICATION - A GUIDELINE FOR STAKEHOLDERS

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STAKEHOLDER ENGAGEMENT IN FSC FOREST MANAGEMENT CERTIFICATION - A GUIDELINE FOR STAKEHOLDERS
STAKEHOLDER ENGAGEMENT
  IN FSC FOREST MANAGEMENT
           CERTIFICATION

 A GUIDELINE FOR STAKEHOLDERS
STAKEHOLDER ENGAGEMENT IN FSC FOREST MANAGEMENT CERTIFICATION - A GUIDELINE FOR STAKEHOLDERS
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    TABLE OF CONTENTS

    1.     Introduction to the FSC System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
    1.1 Who We Are and What We Do . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
    1.2 Representing Sustainability by Operating with three Individual Chambers and their Members . . . 4
    1.3 Principles & Criteria: The Global Normative Backbone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
    1.4 National Standards and the International Generic Indicators (IGIs) . . . . . . . . . . . . . . . . . . . . 8
    1.5 Certification through independent Certification Bodies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
    2.     Stakeholder Engagement within the FSC System . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
    2.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
    2.2 The Role of Network Partners . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
    2.3 Stakeholder Engagement by FSC in the Standard Setting Process . . . . . . . . . . . . . . . . . . 15
    2.4 Stakeholder Engagement by Certificate Holders in Standard Application Process . . . . . . . 17
    2.5 Stakeholder Engagement by Certification Bodies in Standard Conformity Evaluations . . . . 18
    2.6 Public Audit Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
    2.7 Corrective Action Requests (CARs) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
    2.8 Quality Control of Certification Bodies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
    3.     FSC Complaints Management System. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
    3.1 Background Information to Dispute Resolution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
    3.2 FSC Dispute Resolution Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
    4.     Glossary of Key Terms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

    The Forest Stewardship Council® (FSC®) is an independent, not for profit, non-governmental or-
    ganization established to support environmentally appropriate, socially beneficial and economically
    viable management of the world’s forests.
    FSC’s vision is where the world’s forests meet the social, ecological and economic rights and needs
    of the present generation without compromising those of future generations.

    ASI – Accreditation Services International
    CAR – correction action request
    CB – Certification Body
    CH – Certificate Holder
    FMU – Forest Management Unit
    FSC – Forest Stewardship Council
    IGI – International Generic Indicators
    HCV – High Conservation Value
    P&C – Principle and Criteria
    PSU – Policy and Standards Unit
    SDG – Standards Developing Group
    SLIMF – Small and Low Intensity Managed Forests

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1. INTRODUCTION TO THE FSC SYSTEM

___Growing public awareness of forest destruction and degradation has led to increased
demand from consumers to buy wood and other forest products that are from forests
known to be responsibly and well managed. Hence, forest owners and managers increas-
ingly have an interest in proving and communicating their responsible practices to access
these markets. In response to these demands from consumers and forest managers, for-
est certification schemes such as the Forest Stewardship Council (FSC) were developed
and have grown present in the marketplace.1

The goal of FSC is to promote environmentally appropriate, socially beneficial and eco-
nomically viable management of the world’s forests, by establishing a worldwide standard
of recognized and respected Principles* of Forest Stewardship.2

Terms for which a definition is provided in the Glossary of Key Terms are in italics and
marked with an asterisk*. The abbreviations used can be found on the previous page.

1.1 Who We Are and What We Do
The Forest Stewardship Council is a global, democratic and non-profit organization.
FSC provides a connection between forests and end customers, ensuring that products with the
FSC label uphold Principles and Criteria* which bring the highest social and environmental benefits
to forests. FSC certified businesses can use the FSC trademarks to visualize their environmental
efforts and consumers can make informed choices about forest products and can easily identify
sustainable products in the shops.

FSC develops, supports and promotes international, national and provincial standards in line with its
mission; evaluates, accredits and monitors Certification Bodies* which verify the use of FSC stand-
ards; provides training and information; and promotes the use of products that carry the FSC logo.
FSC certification can positively impact workers* and communities, shift governance processes
globally and change economic and environmental conditions in the forest. This impact improves
concerning issues such as conflict over land tenure and use, worker’s* health and safety, biodiversi-
ty conservation, protection of endangered species and participatory forest policy.

1 FSC-STD-01-001 (V4-0) EN FSC PRINCIPLES AND CRITERIA FOR FOREST STEWARDSHIP
2 FSC-STD-01-001 (V5-2) EN FSC PRINCIPLES AND CRITERIA FOR FOREST STEWARDSHIP, § 1 The Forest Stewardship
Council (FSC)

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                                     1.2 Representing Sustainability by Operating with
INTRODUCTION TO THE FSC SYSTEM

                                         three Individual Chambers and their Members
                                     The basic concept of sustainability is often broken up into three dimensions which are the environ-
                                     mental, the social and the economic dimension. Forest resources should meet these diverse needs
                                     of present generations without endangering those of future generations:

                                     a) Environmentally Appropriate
                                     Environmentally appropriate forest management ensures that the production of timber and non-tim-
                                     ber products and ecosystem services* maintain the forest’s biodiversity, productivity and natural
                                     ecological processes.

                                     b) Socially Beneficial
                                     Socially beneficial forest management helps both local people and society at large to enjoy lasting
                                     benefits of intact forests and also provides strong incentives to local people to sustain the forest
                                     resources in the long run.

                                     c) Economically Viable
                                     Economically viable forest management means that forest operations are structured and managed
                                     to be sufficiently profitable, without generating financial profit at the long term expense of the forest
                                     resource, the ecosystem or affected communities.3

                                     3   (footnote 2) Introduction

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In order to address the three mentioned dimensions FSC is governed by international members who
are assigned to one of these three chambers, representing one dimension of sustainability (Figure 1).
FSC is an international membership association with national or regional offices all over the world
and all offices are steered by their members.

Members are from diverse backgrounds and include representatives of environmental and social
non-governmental organizations, the timber trade, forestry organizations, indigenous people’s* or-
ganizations, community forestry groups, retailers and manufacturers, and (forest) certification or-
ganizations, as well as individual forest owners and interested parties. A full list of FSC International
Members is publically available on FSC’s member portal.4

NOTE: In many countries it is possible to become a member at both the national level of the respec-
tive country and at FSC International.

Figure 1: The three-chamber system in the international context

Each chamber - environmental, social and economic - holds equal weight in votes. Within a cham-
ber, organizational members account for 90% of the weight in votes whereas individual members
account for 10%, to reflect the fact that organizational members represent more people than indi-
vidual members.

The chambers of FSC International are further divided into northern and southern members with
50% of the votes respectively. This guarantees that influence is shared equally between different
interest groups and levels of economic power.5

4   FSC Forest Stewardship Council® Public Member Search. http://chportal.fsc.org/PublicMemberSearch, 5.10.2016
5   FSC Forest Stewardship Council® Governance. https://ic.fsc.org/en/about-fsc/governance-01, 17.10.2016

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                                 Both individual and institutional members have the right to attend the General Assembly, FSC’s
                                 highest decision-making body. They can formulate, submit and vote on General Assembly motions
                                 which fundamentally affect the way FSC is run. FSC members can also stand as and vote for can-
                                 didates for the Board of Directors.

                                 The General Assembly takes place once per year at national level and every 3 years at international
                                 level where central decisions about FSC are made.
Introduction To the FSC System

                                                                                                                 ©
                                                                                                                     FSC GD Juan Lopez

                                 1.3 Principles & Criteria: The Global Normative Backbone
                                 There are 10 recognized and respected Principles* of Forest Stewardship the FSC promotes for
                                 responsible forestry, with a set of 56 underlying Criteria which identify more detailed aspects. These
                                 Principles and Criteria (P&C)* apply to tropical, temperate and boreal forest, and many of them are
                                 also used for plantations and partially replanted forests.

                                 To assess the compliance with the Principles and Criteria there are concrete Indicators* which can
                                 be verified by the certifier on-site (Chapter 1.4).

                                 So, from the concept to the implementation, the FSC standard is built upon Principles – Criteria –
                                 Indicators.

                                 The FSC Principles and Criteria are valid worldwide for achieving FSC forest management certifi-
                                 cation. Adaptations at national level and difficulties of interpretation of the P&C will be addressed
                                 in national and local Forest Stewardship standards in order to reflect the diverse legal, social and
                                 geographical contexts of forests in different parts of the world.

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Table 1: Current (V4-0) and revised (V5-0) Principles of Forest Stewardship (based on FSC-STD-01-001
(V4-0) and FSC-STD-01-001 (V5-0))

Table 1 shows the 10 Principles of FSC, which were updated from V4-0 to V5-0 in 2014. From 2018
all nationally approved forestry standards will be based on this Version 5-0 which will be applied
through the implementation of the IGIs (Chapter 1.4).

The P&C are a complete package to be considered as a whole, and their sequence does not repre-
sent an ordering of priority. They should be used in conjunction with national and international laws
and regulations. FSC intends to complement, not supplant, other initiatives that support responsible
forest management worldwide.6

6   (footnote 2) § 3. Scope

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                                     1.4 National Standards and the International Generic
                                         Indicators (IGIs)
INTRODUCTION TO THE FSC SYSTEM

                                                                                                                       © FSC IC Christian Irrgang

                                     As set out above, the FSC Principles and Criteria form the global basis for achieving FSC forest
                                     management certification. At the national/regional level the internationally valid P&C are adapted
                                     to the national context and a more detailed standard is formulated that suits the given forests and
                                     circumstances. This process is outlined below.

                                     Proposals directed to the Policy and Standards Unit (PSU)* of FSC International in order to de-
                                     velop standards may be made by the FSC Board of Directors, the FSC General Assembly, or by
                                     FSC members, FSC accredited National Initiatives, members of FSC staff or staff of Accreditation
                                     Services International (ASI).7 Where there is no accredited National Initiative, there is the option to
                                     form a stand-alone Standards Development Group (SDG)* registered by FSC. Development of FSC
                                     Forest Stewardship Standards shall not commence where there is no FSC registered Standards
                                     Development Group.8

                                     Once FSC International has registered the application for a national standard, the Standards Devel-
                                     opment Group (SDG) with agreed terms of reference, a work plan and a budget for the development
                                     of the proposed national standard is formed.9

                                     The SDG is composed of an equal number and at least two representatives from each of the three
                                     chambers and an equal number of people (or equal weighting) from each chamber. Where a region-
                                     al process is proposed, each nation within the region should have at least one representative in each
                                     chamber of the regional Standards Development Group.10

                                     After that the SDG must announce the standard development to all key stakeholder groups within the
                                     territory and shall be responsible for setting up a Consultative Forum for the standards development
                                     process. The role of the Consultative Forum shall be to ensure that all stakeholders who may be affected

                                     7  FSC-STD-60-006 (V1-2) EN PROCESS REQUIREMENTS FOR THE DEVELOPMENT AND MAINTENANCE OF NATIONAL
                                        FOREST STEWARDSHIP STANDARDS, §1.1
                                     8 (footnote 7) § 4
                                     9 (footnote 7) § 5.1
                                     10 (footnote 7) § 4.2

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by the standard have the opportunity to comment, formally, during the standard development process.11

The role of the Standards Development Group members is to examine and comment on drafts, to
review and advise on comments submitted by stakeholders and to make suggestions for wording
in order to address aspects that are important for reaching consensus support of all members of
the Standards Development Group.12

After sufficient reviewing and testing (if necessary) the standard can be submitted to the PSU and
the FSC Board of FSC International for approval.

In cases were no SDG could be developed, a Certification Body (CB13)* is used to develop a nation-
al/ regional standard. The CB has to consult widely during the development process and also uses
the IGIs as the framework to work from.

To facilitate the implementation of the FSC Principles and Criteria (Table 1) into a national standard,
FSC has developed a set of International Generic Indicators (IGIs)*. These International Generic
Indicators serve as framework for the development of national indicators where no exist. It is ex-
pected that the IGIs will enable more efficient standard development processes at the national and
regional levels and also that national standards will all be more consistent when compared against
each other.

In regions or countries currently without approved Standards, the IGIs will become the applicable
standard and replace the former Certification Body-developed standards.

1.5 Certification through independent Certification Bodies

The local verification of compliance with the FSC Standards (explicitly the Criteria & Indicators) is
done by independent quality management companies: the Certification Bodies (CBs). There are
three types of evaluations* that are carried out in order for an organization to receive and maintain
a FSC certificate:

11 (footnote 7) § 6.2
12 (footnote 7) § 7.2
13 The Certification Body (abbreviated with “CB”) was previously called Conformity Assessment Body (abbreviated with “CAB”).
   Either one of the formulations may still be discovered; however the first one shall be used as the current term.

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                                 Pre-evaluations
                                 Any forest management unit (FMU) of the following categories needs a pre-evaluation:
INTRODUCTION TO THE FSC SYSTEM

                                 a) Plantations larger than 10.000 ha;
                                 b) All non-plantation forests larger than 50.000 ha;
                                    NOTE: the thresholds in a) and b) refer to the total area included in the scope of evaluation
                                    (either as a single FMU or as multiple or group FMUs).
                                 c) FMUs containing high conservation value* attributes, unless the whole area meets the require-
                                    ments for classification as a “small forest” (Box 1).14

                                 The Certification Body carries out a pre-evaluation observing forest management activities and
                                 speaking with stakeholders such as employees, the local population, and others who may be inter-
                                 ested in the forest management practices.

                                 The result of the pre-evaluation is a report that discusses the strengths and weaknesses of the
                                 organizations’ forest management activities. Key weaknesses will need to be addressed before the
                                 main evaluation.

                                    The pre-evaluation is optional for forest smallholders15. In case smallholders are not sure if
                                    they fulfil the FSC requirements it makes sense to have the pre-evaluation.

                                    In the case of group certification16 the Certification Body is going to check the conformity
                                    of the group entity with the FSC Standards.

                                 Box 1: Pre-evaluations for smallholders and group certification

                                 A mandatory part of the pre-evaluation is a consultative phase in which key stakeholders are iden-
                                 tified and consulted. This consultative phase shall be completed prior to the initiation of the main
                                 evaluation.

                                 NOTE: This consultation does not replace the stakeholder consultation for the main evaluation
                                 (Chapter 2.5).

                                 In a voluntary pre-evaluation (in case of smallholders) the evaluation may be carried out in confi-
                                 dence, if this is requested by the Certificate Holder.17

                                 Main and re-evaluations
                                 The main evaluation process is an in-depth-review of the forest management systems and their
                                 results on-site. The Certification Body sends experts to assess social, economic and environmental
                                 conditions in the forest being evaluated.

                                 14 FSC-STD-20-007 (V3-0) EN FOREST MANAGEMENT EVALUATIONS, § 3.1.1
                                 15 Forest Management Units of up to 1000 ha. may be classed as small and low intensity managed forest units (SLIMF). Low
                                    intensity refers to forests with low rates of harvesting (for detailed definitions see FSC-STD-01-003). In this case there are
                                    streamlined procedures to lower the costs and expenditures in order to facilitate the entrance into certification.
                                 16 The group entity is responsible to the certification body for ensuring that the requirements of the FSC Principles and Criteria
                                    are met in all forest parcels being part of the group. The group entity may be an individual (e.g. a “resource manager”), a coop-
                                    erative body, an owner association or other similar legal entity. The applicable standard is FSC-STD-30-005 FSC Standard for
                                    Group Entities in Forest Management Groups.
                                 17 (footnote 14) § 3.3.3

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11

At the end of the evaluation, the assessment team reports any aspects and areas where manage-
ment does not meet the applicable requirements (as set out in the relevant FSC Standard) to the
forest manager, known as “non-conformities”. If these are minor non-conformities, the certification
body can issue a certificate, on condition that actions will be taken to deal with the non-conformities
by the time of the next audit*. If these are major non-conformities, the certification body will not issue
a certificate until the non-conformities have been solved (Chapter 2.7).18

Forest Management certificates are valid for five years and subject to annual checks. For smallhold-
ers, again, the procedures differ (Box 1). The certification body shall initiate the general stakeholder
consultation and interview a sufficient variety and number of people affected by or involved in the
forest management (Chapter 2.5).

Re-evaluation takes place after the five year period the certificate is valid for. The re-evaluation
process is similar to the main evaluation but can be based on the evaluations already made during
the first five year period of certification.19

Surveillance evaluations
Once per year the certification body carries out a surveillance evaluation to moni-
tor the certificate holder’s continued conformity with applicable certification requirements*.
Special attention shall be paid to any kind of structural changes occurring in the forest managed and in
the organization managing it, such as a change in forest area or a change in the management system.

As with the main evaluations stakeholder consultations shall be part of the annual surveillance
evaluations (Chapter 2.5).20

18 (footnote 14) § 5
19 (footnote 14) § 7
20 (footnote 14) § 6

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                         2 . STAKEHOLDER ENGAGEMENT WITHIN
                             THE FSC SYSTEM
STAKEHOLDER ENGAGEMENT

                         ___The basic aspects of stakeholder engagement*, e.g. consultations, shall be illustrated
                         in this chapter.

                         2.1 Introduction
                         National and local stakeholders can provide relevant information about the applicant’s conformity
                         with the respective FSC Standard. These stakeholders include national and local government and
                         non-government organizations (NGOs) involved in forest management, as well as individuals and
                         members of communities directly affected by the forest management.21

                         In the context of FSC certification a Stakeholder is any individual or group whose interests are
                         affected by the way a forest is managed. Engagement is the process by which the FSC or one of
                         its Network Partners, the Certificate Holder or the Certification Body communicates, consults and
                         provides for the participation of interested and affected stakeholders. Doing so ensures that their
                         concerns, desires, expectations, needs, rights and opportunities are considered in the establish-
                         ment, implementation and updating of forest management activities.22

                         There are three points of potential stakeholder engagement: In the standard setting process, in the
                         standard application process and in the verification process. These three points can also be viewed
                         from an active perspective indicating three relations:

                         21 FSC-STD-20-006 (V3-0) EN STAKEHOLDER CONSULTATION FOR FOREST EVALUATIONS
                         22 (footnote 2)

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13

                                1. Stakeholder – FSC (1* in Figure 2),
                       2. Stakeholder – Certificate Holder (2* in Figure 2) and
                         3. Stakeholder – Certification Body (3* in Figure 2).

Figure 2: Compliance hierarchy and possible points of stakeholder engagement in the FSC System. In
this case organization is defined as the forest group or the group manager.

Before approaching these three points of stakeholder engagement (Chapter 2.3 to 2.5) some back-
ground information on the role of the FSC as a global organization will be given (Chapter 2.2 on
Network Partners).

Chapters 2.6 to 2.8 will cover information for stakeholder engagement and standard application
processes which is relevant for dispute resolutions. The topic of dispute resolutions will then be
discussed in chapter 3 where the necessary steps for formal complaints* are explained.

Guidelines for Stakeholders
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                         2.2 The Role of Network Partners
STAKEHOLDER ENGAGEMENT

                         FSC is a global network of partners that share the same goal. There are three types of Network
                         Partners:

                         1. FSC National Office: a legally established and independent FSC partner organization promoting
                            responsible management of the world’s forests on behalf of FSC at the national level, on the ba-
                            sis of a formal contract (cooperation agreement). National Offices shall have a multi-stakeholder
                            governance structure, similar to that of the International Office (Chapter 1.2).
                         2. FSC National Representative: an individual working on behalf of FSC in his/her country to
                            serve as a national point for information and to promote responsible management of the forests
                            under a formal contract (cooperation and service agreement).
                         3. FSC National Focal Point: an individual with a specified and agreed task for his/her country,
                            accomplished on a voluntary basis and under a formal contract (agreement). The National Focal
                            Point does not represent FSC.

                         On top of Network partners there are FSC Regional Offices which are a branch of FSC Interna-
                         tional located in a region (continent or sub-continent) where no national offices could be set up yet.
                         Regional Offices represent FSC and set priorities for development in the region and develop plans
                         for those areas where FSC is not directly represented.23

                         The core tasks of National Offices are the standard setting of national standards and the public re-
                         lations via information. Regarding the engagement of stakeholders, there are two concrete actions
                         that can be taken:
                         – support the CB with a list of potential stakeholders (additional to own efforts of the CB);24
                         – support stakeholders by informing them through media (for example this brochure) or directly
                           when requested.

                         23 FSC AC STATUTES EN July 2013, § 37th
                         24 (footnote 21) § 2

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15

2.3 Stakeholder Engagement by FSC in the Standard
    Setting Process
There are two possible ways of stakeholder engagement in FSC standard setting processes. The
most direct way is through FSC membership whereas indirect engagement is also possible for
non-members, as follows:

1. Direct engagement is intended for FSC members (either as a member of a National Office
   where it exists or as a member of FSC International). As a member you have the right to partici-
   pate in the General Assembly (either the national ones or the international one, depending on the
   type of membership). The General Assembly takes place every year at national level and every 3
   years at international level where central decisions about FSC are made. Core matters dealt with
   by the General Assembly are:

   – Reviewing the FSC Principles and Criteria;25
   – Reviewing the financial statements of the organization for the previous period;
   – Appointing and revoking the appointment of members of the board of directors;
   – Any amendments to the statutes;26
   – The admittance or exclusion of members.27

2. Indirect engagement in the standard setting process is possible for stakeholders who are not
   members (either in case a National Office is established but stakeholders are not members or
   in case no National Office exists and hence no membership at national level is possible). When
   standards are developed or revised, standard drafts have to be published for consultation. An
   official announcement of a new standard under development must be made and a Consultative
   Forum must be set up by the Standards Development Group (Chapter 1.4).28

   The Consultative Forum shall be open to any stakeholder without limitation in numbers and it shall
   ensure that every stakeholder affected by the standard is able to make comments throughout
   every stage in the standard development process. For regional standard development processes
   a consultative forum shall be set up in each country affected.29

   The standard draft is circulated to all identified key stakeholders of the consultative forum in order
   to receive feedback.30 Comments are supposed to be made on formal comment forms that will
   be attached to the draft. The Standards Development Group shall be proactive in seeking input
   from representatives of different stakeholder groups. Communication needs to be appropriate to
   the stakeholder’s ability to access the information, as some groups may not have access to email
   or might be illiterate.

25 This first matter applies only to the general assembly of the FSC International. In case of a National/Regional Office the general
   assembly votes on the adoption of the national Forest Management standard with its regionally adapted indicators (Chapter 1.4).
26 Except for a change of the organizations purpose which is reserved to an extraordinary general assembly. Extraordinary
   General Assemblies shall resolve exclusively the following matters: A change of the Organization’s purpose or Dissolution of the
   Organization.
27 (footnote 23)
28 (footnote 7) § 2, 6.1
29 (footnote 7) § 6.2-6.4
30 (footnote 7) § 7.7

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                         For consideration as formal comments, stakeholders shall be made aware:

                            a) that comments shall be submitted in the working language(s) established for the Standards
                                Development Group;
STAKEHOLDER ENGAGEMENT

                            b) of the address to which they need to be sent;
                            c) of the period for submitting comments;
                            d) that they shall provide their full name, contact details and the capacity in which they are com-
                                menting;
                            e) that all other comments shall be considered as informal comments. Whenever possible, in-
                                formal commentators shall be contacted and encouraged to make their comments formal.
                                Informal comments will be responded to in so far as capacity allows;
                            f) that all comments (formal or informal) should be attributed, and will be considered as being
                               publicly available, unless the contributor explicitly requests that the comments should be treat-
                               ed confidentially. Anonymous comments shall not be considered.31

                                                                                                             ©
                                                                                                                 FSC GD Juan Lopez

                         The period to submit comments on the first draft for public consultation shall be a minimum of sixty
                         (60) days from the date of publication. The period for consultation on intermediate drafts shall be a
                         minimum of thirty (30) days from the date of publication. The period for consultation on the final draft
                         prior to decision making shall be sixty (60) days from the date of publication.

                         NOTE: The same procedures being applied for setting of new standards shall also be applied to
                         standard-revision processes.32

                         The basis of each standard is the internationally consistent set of Principles & Criteria (Chapter 1.3).

                         31 (footnote 7) § 7.9
                         32 (footnote 7) § 7.8, 12.5

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2.4 Stakeholder Engagement by Certificate Holders in
    Standard Application Process
The Certificate Holder managing the forest is required to engage stakeholders in a range of activ-
ities that are written down in the Principles & Criteria*. Basically, the Certificate Holder is required
to involve potential stakeholders (affected and/or interested) before, during and after management
activities. The centrepiece of engagement by the Certificate Holder lies in the Certificate Holder’s
management plan* which should reflect input from stakeholders.

Table 2 shows the Principles & Criteria and references made to stakeholder engagement in the re-
spective principle or criterion. Criteria that do not directly name stakeholder engagement but include
it in the subsequent indicators are marked with an asterisk ((*)).

In most cases the engagement aims at preventing conflict and balancing diverging interests of
stakeholders curious about the forest managed or directly affected by the forest management ac-
tivities. The Certificate Holder has the obligation to prevent conflicts by appropriate and pro-active
steps towards stakeholders.

Table 2: Principles & Criteria with references to stakeholder engagement (based on FSC-STD-01-001 (V5-0))

Guidelines for Stakeholders
18
STAKEHOLDER ENGAGEMENT

                         2.5 Stakeholder Engagement by Certification Bodies in
                             Standard Conformity Evaluations
                         The Certification Body shall consult with a range of stakeholders who can provide relevant informa-
                         tion on the applicant’s conformity with the environmental, legal, social, and economic requirements
                         of the Forest Stewardship Standard. Table 3 shows some examples for potentially affected and thus
                         typically consulted stakeholders in relation to the current Principles & Criteria. Sometimes only the
                         directly envisaged stakeholder groups need to be consulted while for other principles a wider range
                         of stakeholders is appropriate.

                         Relevant information from consultations may include examples of non-conformity, as well as con-
                         firmation of conformity with:

                         a) Legal requirements (FSC Principle 1);
                         b) Social requirements (FSC Principles 2, 3, 4, 9);
                         c) Technical or economic requirements (FSC Principles 5, 7, 8, 10);
                         d) Environmental requirements (FSC Principles 6, 9, 10).33

                         Information and opinions given by consulted stakeholders shall be evaluated objectively and mean-
                         ingfully, and affect the certification decision only in so far as they provide evidence of conformity or
                         non-conformity within the requirements of the applicable Forest Stewardship Standard.34

                         33 (footnote 21) § 1.1, 1.2
                         34 (footnote 21) § 1.4.3

                                                                                                      Guidelines for Stakeholders
19

Table 3: Examples of stakeholder groups (based on FSC-STD 60-006 (V1-2), FSC-STD 20-007 (V3-0))

Guidelines for Stakeholders
20

                         1. Consultation during main evaluations
                         The certification body should aim to ensure that any stakeholder who wishes to bring something to
                         his attention has the possibility to do so prior to the decision to grant a certificate.35 For this purpose
                         CBs can also contact FSC national offices for support (Chapter 2.1).
STAKEHOLDER ENGAGEMENT

                         The stakeholders contacted should be appropriate to the scale of the organization’s operations.
                         This means that e.g. locally active Certificate Holders are going to have a different set of stakehold-
                         ers than nationally active Certificate Holders.36

                         The identified stakeholders shall be informed at least six (6) weeks prior to the start of the main
                         evaluation site visits:

                         a) that an FSC forest evaluation is due to take place;
                         b) the start date of the evaluation;
                         c) the applicant’s name and the location of the forest area to be assessed;
                         d) how to acquire a copy of the Forest Stewardship Standard to be used for the evaluation;
                         e) that the certification body is seeking the views and opinions of stakeholders as to whether the
                            applicant’s forest management complies with the requirements of the standard;
                         f) how stakeholders may contact the certification body in confidence to let the certification body
                            know of their views and opinions;
                         g) that the team will make arrangements to allow stakeholders to meet with them during the evalu-
                            ation;
                         h) of the existence of the certification body’s mechanisms for resolution of complaints or disputes;
                         i) that the source of any information is kept confidential on request.37

                         The certification body may use a variety of means to inform stakeholders about the information
                         listed above, appropriate to the group being contacted. Techniques may include emails in the lan-
                         guage of the stakeholder, personal contact by phone or letter, a notice in the national or local press/
                         media (e.g. radio), announcements at the village level via posts or contacts existing between stake-
                         holders and the Certificate Holder or face to face meetings.38

                         2. Consultation during surveillance evaluations
                         The certification body shall conduct stakeholder consultation during surveillance evaluations to ver-
                         ify continued conformity of the certificate holder with relevant certification requirements*. Consulta-
                         tion techniques and confidentiality of information shall follow the same requirements as in the main
                         evaluation.

                         Comments received from stakeholders after the main evaluation shall be recorded, evaluated and
                         documented at the following surveillance evaluation, unless provided as part of a formal complaint
                         or indicating a major non-conformity requiring immediate action (Chapter 2.7).39

                         35   (footnote 21) § 2.2
                         36   (footnote 21) § 2.5
                         37   (footnote 21) § 2.6
                         38   (footnote 21) § 2.8
                         39   (footnote 21) § 7.1-7.3

                                                                                                        Guidelines for Stakeholders
21

3. Consultation in case of missing national standards and SLIMF* certification
For main evaluations in a context where no FSC approved national, regional or sub-national Forest
Stewardship Standard exists, the stakeholder notification shall include:

a) that the standard to be used for the evaluation is available on the Certification Body’s website or
   on request;
b) that the standard may be modified to take account of stakeholder comments, and that com-
   ments and suggested modifications to the standard are welcome.

In case of forest management units which meet the eligibility criteria for small or low intensity FMUs
(SLIMF, see footnote 19) the certification body should work with the applicant to identify local, and
where appropriate, national stakeholders, and to agree on the method of communication.

Methods of communication may include those identified above. The certification body may del-
egate some or all of the implementation of this communication to the applicant, but shall ensure
that stakeholders have access to the same information as in a common case, prior to the main
evaluation taking place. The certification body shall ensure that there is adequate opportunity for
stakeholders to comment directly to the Certification Body. In areas where tensions with stakehold-
ers are known to exist certification bodies shall carry out direct consultation with local and, where
appropriate, national stakeholders.40

                                                                              ©
                                                                                  FSC IC Christian Irrgang

40 (footnote 21) § 2.7, 2.9

Guidelines for Stakeholders
22

                         2.6 Public Audit Reports
                         Public Audit Reports (so called “forest certification public summary reports”) are the main tool to
                         make information about FSC certified forest management publicly available. They are the basis for
STAKEHOLDER ENGAGEMENT

                         checking conformity of theory (standards) with reality (actual forest management). Public Audit Re-
                         ports are prepared or updated after every evaluation and must contain predetermined information
                         so that comparison is possible.

                         They must include a systematic presentation of stakeholder comments received together with the
                         conclusions and a description of the follow-up action from the certification body. Similar stakeholder
                         comments may be grouped by issues.41

                         The certification body shall not identify individual stakeholders or stakeholder groups in the report
                         without their prior informed consent. Within three (3) months of the certification decision, the cer-
                         tification body shall actively inform the consulted stakeholders who provided written comments or
                         who requested an update on how their concerns were addressed.42

                         The reports shall be made available in:

                         a) one of the official languages of FSC for certificates that cover a total forest area of more than
                            1,000 ha in the scope, and
                         b) at least one of the official languages of the country in which the certified forest is located, or the
                            most widely spoken language of the indigenous people in the area in which the certified forest is
                            located.43

                         Where can you find the reports?

                         The public summary reports, including translations as required, shall be published on the FSC data-
                         base of registered certificates (hereafter called database) before a certificate is issued or re-issued.
                         Annual updates shall be added to the published summary report or published separately on the
                         database no later than ninety (90) days after a surveillance evaluation on-site.44

                         Every Certificate Holder has a short profile in the database which is publicly accessible at http://
                         info.fsc.org. An organization can be found in the database via diverse search options: Its license
                         code,45 its certificate code,46 its organizational key figures (e.g. name, country etc.) and/or its prod-
                         ucts (Figure 3).

                         41 FSC-STD-20-007b (V1-0) EN FOREST MANAGEMENT EVALUATIONS ADDENDUM - FOREST CERTIFICATION PUBLIC
                         SUMMARY REPORTS, § 4.1.3
                         42 (footnote 21) § 6.1-6.3
                         43 (footnote 41) § 2.1
                         44 (footnote 41) § 3
                         45 The licence code is used for product labelling and promotional claims.
                         46 The certificate code is used on invoices and delivery documents.

                                                                                                       Guidelines for Stakeholders
23

Figure 3: FSC certificate search at info.fsc.org

What will you find in the reports?

The report highlights the most important features and outlines the specific format to be used (Box
2 below)47. There are two exceptions:

a) The elements marked with an asterisk (*) in the table are NOT required in the case of certificates
   issued to single SLIMF* FMUs.48
b) Forest certification public summary reports for group certificates49 shall include an up-to-date list
   of all non-SLIMFs group members with name, contact details and the geographical location of
   their FMUs in the scope of the certificate, unless national legal restrictions do not allow publication
   of this kind of information (this needs to be specified in the public summary report).

47 Data presented in the reports should be in metric system units. If non metric system units are used the report shall provide
   conversion rates together with any assumptions made in order to make conversion into metric units possible (FSC-STD-20-
   007b, § 4.1).
48 See footnote 15 for a definition of SLIMF FMUs.
49 See footnote 16 for the definition of group certificates.

Guidelines for Stakeholders
24

                         1 Description of forest management

                         1.1 A description of the forest, land use history and regional context
STAKEHOLDER ENGAGEMENT

                         1.2 A general description of the management system (e.g., uneven-aged management,
                             even-aged management, rotation length, silvicultural prescriptions);
                         1.3 A summary of the management plan*, including a description of:
                             1.3.1 the management objectives*;
                             1.3.2 the forest resources (land use and ownership status, socio-economic conditions,
                                    forest composition, profile of adjacent lands);
                             1.3.3 Geographical location of the non-SLIMFs FMU(s) in the scope of the certificate:
                                    i) Latitude E/W ### degrees ## minutes
                                    ii) Longitude N/S ### degrees ## minutes
                                    NOTE: the coordinates should refer to the center of a FMU.
                             1.3.4 The management structures (e.g. management structure, division of responsibili-
                                    ties, use of contractors, provision of training, etc). implemented by the certificate
                                    holder;
                             1.3.5 The silvicultural and/or other management systems being implemented (incl.
                                    harvesting techniques and equipment, rationale for species selection);
                             1.3.6 The environmental safeguards;
                             1.3.7 The management strategy for the identification and protection of rare, threatened
                                    and endangered species;
                             1.3.8 The certificate holder’s procedures for monitoring growth, yield and forest dy-
                                    namics (incl. changes in flora and fauna), environmental and social impacts, and
                                    costs, productivity, and efficiency;
                             1.3.9 Summarized quantitative data on the use of pesticides (names and quantities of
                                    pesticides applied, size of area treated annually).
                         1.4 A description of any area of forest which the certificate holder has chosen to exclude from
                             the scope of the certificate together with an explanation of the reason for its exclusion
                             and description of the controls that are in place to ensure that there is no risk of confusion
                             being generated as to which activities or products are certified, and which are not.

                         2 Standard(s)

                         2.1 Reference to the standards used […] including the version number and date of finalisation.
                             NOTE: The summary report shall include a statement and/or link to the website(s) where
                             the standard(s) used can be downloaded or requested.

                         2.2 A description of the process of local adaptation of the standard, if applicable.

                                                                                                   Guidelines for Stakeholders
25

  3 The evaluation process

  3.1 The evaluation dates: (specify actual dates or month, year and duration);
  3.2 A general description of the evaluation including, if applicable, pre-evaluation visits.
      The description should give an overview of what was audited, audit methods and time
      allocation when significant;
  3.3 A general description of the consultation process with stakeholders.

  4 Observations

  4.1 A general presentation of the observations on which the certification decision is based,
      including:
      4.1.1 a list of main strengths and weaknesses with respect to the overall conformity
             with the Forest Stewardship Standard used for the evaluation;
      4.1.2 a summarized presentation of findings with clear information to enable the reader
             to make an easy correlation between the requirements of each of the criteria of the
             Forest Stewardship Standard used and the performance of the certified operation;
      4.1.3 Clear and systematic presentation of the comments received from stakeholders
             (who are not members of the enterprise under evaluation) before, during or after
             the evaluation, and the corresponding follow-up action and conclusions from the
             certification body;
             NOTE: similar stakeholder comments may be grouped by issues.
      4.1.4 a description of any preconditions that had been issued, and the actions taken by the
             certificate holder to close out those preconditions prior to the issue of the certificate.

  5 Certification decision

  5.1 A clear statement that the forest has been certified by the certification body as meeting
      the requirements of the specified standard, the date of certification, and the expiry date
      of the certificate.
  5.2 A list of all non-conformities that the managers are required to correct in order to maintain.

Box 2 : Format for Public Audit Reports (excerpt from FSC-STD-20-007b (V1-0))

Guidelines for Stakeholders
26

                         2.7 Corrective Action Requests (CARs)
STAKEHOLDER ENGAGEMENT

                         Certification Bodies evaluate during audits whether or not an organization is in line with the applica-
                         ble FSC Standards (Figure 4). In order to comply with a criterion compliance with all its indicators is
                         necessary. Non-compliance of a criterion is referred to as a minor or major non-conformity (Table 4).
                         All non-conformities that are identified by the certification body during an evaluation shall systemat-
                         ically be recorded in the evaluation report or associated checklists.

                         The critical question is whether non-conformities lead to the fundamental failure of fulfilling a FSC
                         Criterion. If yes, this constitutes a major non-conformity. The cumulative impact of a number of mi-
                         nor non-conformities may represent a fundamental failure or total breakdown of a system and thus
                         constitute a major non-conformity as well.

                         Non-conformities lead to Corrective Action Requests (CARs), suspension* or withdrawal of the
                         certificate.

                         NOTE: Suspension means a temporary invalidation of the Certificate Holder’s status as certified
                         until the non-conformities have been corrected. Withdrawal means the decision of the Certification
                         Body or the Certificate Holder himself to cancel the FSC certification. To become FSC certified
                         again, the organization must initiate the certification process from the beginning, starting with the
                         pre- and main evaluation.

                         Minor non-conformities must be fully corrected within one year with an exceptional extension for
                         another year in cases where the correction lies beyond the control of the responsible forest manager.

                                                                                                     Guidelines for Stakeholders
27

Major non-conformities must be fully corrected within three months with the same exceptional
extension for another three months if it lies beyond the control of the responsible forest manager.
Major non-conformities usually require immediate actions taken to conform to the FSC standards –
e.g. immediate stop in using pesticides.

Table 4: Distinguishing minor and major non-conformities and CARs (based on FSC-STD-20-007 (V3-0))

The certification body shall determine whether the corrective action has been appropriately and
fully implemented within given timeline. If the action taken is not considered adequate, either minor
non-conformities become ‘major’ non-conformities and must be corrected within a maximum peri-
od of three (3) months or major non-conformities lead to the suspension of the certificate. If five (5)
or more major non-conformities appear in one evaluation, the certificate shall be suspended as well.
Major non-conformities cannot in any case be downgraded to minor non-conformities.50

Figure 4: Conformity evaluation process by CBs

50 (footnote 14) § 8.11-8.13

Guidelines for Stakeholders
28

                                   2.8 Quality Control of Certification Bodies
FSC COMPLAINTS MANAGEMENT SYSTEM

                                   Similar to the evaluations of forest enterprises (Chapter 2.6); Certification Bodies are also under
                                   scrutiny. Every Certification Body is evaluated annually in order to assess its qualification to carry
                                   out FSC Audits.51 These evaluations are performed by Accreditation Services International (ASI), a
                                   subsidiary of FSC International (Figure 2).

                                   ASI formulates corrective action requests (CARs) towards the CB if non-conformities on behalf of
                                   the CB are observed. Non-conformities on behalf of the CB are distinguished in minor and major
                                   non-conformities. If a CB doesn’t correct a minor CAR within the given time (12 months) the minor
                                   CAR becomes a major CAR. If a major CAR is not corrected within three (3) months the CB loses
                                   its status as accredited certifier (suspension).52

                                   When a CB becomes suspended the already issued certificates hold their validity until they expire.
                                   The CB is still going to be responsible for surveillance evaluations until the regular expenditure of
                                   the certificate (the time span for FSC certificates is 5 years). New certificates cannot be issued, but
                                   already started certification processes can be finalized.

                                   NOTE: When suspending a CB this can be restricted by ASI to a specific region or continent or for
                                   Forest Management certificates or Chain of Custody certificates only.

                                   If the CB cannot correct the respective CARs that led to suspension within six (6) months, its status
                                   as accredited certifier is terminated. Affected Certificate Holders need to approach another accred-
                                   ited CB and must restart the certification process with a main evaluation. Their certificates at the
                                   given time are valid for further three (3) months from the moment of the CB’s termination*.53

                                   Stakeholders are enabled to make complaints* against the performance of Certification Bodies,
                                   which are dealt with by ASI. Complaints should nevertheless be directed first of all to the relevant
                                   Certification Body and processed according to the Certification Body’s own complaint procedure.54
                                   The topic of formal complaints and subsequent procedures will be dealt with in Chapter 3.

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                                   51   ASI-PRO-20-105 (V5-0) SURVEILLANCE & SAMPLING, § 4.1.2
                                   52   ASI-PRO-20-106 (V4-0) ASSESSMENT-FINDINGS, § 6
                                   53   ASI-PRO-20-102 (V4-0) EXTENSION, REDUCTION, SUSPENSION, TERMINATION, § 7, 8
                                   54   FSC-PRO-01-008 (V2-0) EN PROCESSING COMPLAINTS, § 2

                                                                                                                      Guidelines for Stakeholders
29

3 . FSC COMPLAINTS MANAGEMENT SYSTEM

                                                                               ©
                                                                                   FSC IC Christian Irrgang

___The FSC complaints management system provides a framework for the resolution of
disputes* that stakeholders may have with the FSC Board of Directors, FSC and/or its
affiliates, ASI, FSC accredited Certification Bodies or FSC Certificate Holders.55

3.1 Background Information to Dispute Resolution
Before dealing with the concrete possibilities for dispute resolution two key terms shall be defined.
The term “dispute*” is used as an umbrella term for the terms “appeal*” and “complaint*” in this
brochure which are defined as following:

a) Complaint: formal expression of dissatisfaction by any person or organization presented as a
   complaint to FSC, relating to the activities of the FSC certification scheme and/or the FSC ac-
   creditation program, where a response is expected.
b) Appeal: request by a party subject to a decision for reconsideration of any adverse decision
   made by the FSC with regard to the FSC Certification Scheme and/or the FSC Accreditation
   Program.56

Now, in general, FSC envisages a lowest level principle which means that disputes should always
be addressed by discussion and negotiation at the lowest level possible. In case of concerns about
a certified operation, the lowest level is the certificate holder. Therefore stakeholders are strongly
encouraged to follow this principle and formal procedures should only be adopted as a last resort.

55 FSC-STD-20-001 (V3-0) EN GENERAL REQUIREMENTS FOR FSC ACCREDITED CERTIFICATION BODIES
56 (footnote 55) p. 5-6

Guidelines for Stakeholders
30

                                   There are five possible levels for complaints and follow-up processes of dispute resolution which are
FSC COMPLAINTS MANAGEMENT SYSTEM

                                   further explained in the following subsections of this document (Figure 5):

                                   1. Stakeholder to Certificate Holder
                                   2. Stakeholder to Certification Body
                                   3. Stakeholder to ASI
                                   4. Stakeholder – Violations of FSC’s Policy for Association
                                   5. Stakeholder to FSC

                                   Figure 5: Levels of dispute resolution

                                   Stakeholder – Certificate Holder
                                   Stakeholders who have complaints about the operations of a Certificate Holder should directly
                                   contact the managers responsible for those operations in the certified company. Contact details of
                                   Certificate Holders can be found through a search at http://info.fsc.org/. Complaints should always
                                   be made on the basis of the applicable standards. Beforehand, it might be helpful to read the public
                                   audit reports (Chapter 2.6) of the concerning Certificate Holder. There is a possibility that there are
                                   already CARs on the matters raised by the stakeholder.

                                   If it is not clear whether an organization is certified, this can be checked in the certificate database
                                   info.fsc.org. Organizations that can be found in this database have a valid57 FSC certificate and
                                   hence are obliged to fulfil FSC Standards. If FSC certified, the organization is obliged to have a
                                   mechanism in place to deal with stakeholder complaints.

                                   If the issue in question cannot be resolved at the lowest level (in this case the Certificate Holder), a
                                   complaint can be lodged to the Certification Body who issued the certificate. Certification Bodies
                                   must have their own complaints procedures to deal with disputes (next level below).58

                                   Stakeholder – Certification Body
                                   Complaints should be directed to the Certification Body in cases where the complaint could not be
                                   resolved directly with the Certificate Holder or the complaint is filed directly against the performance
                                   of a Certification Body (Figure 5). The complaints procedures must be explained by the Certification
                                   Body during the main audit (Chapter 1.5) of a certification applicant. Also, information about the
                                   CBs complaints procedures must be published on the CBs website.59 The CB’s contact details can
                                   be found via the certificates database.

                                   57 It is also possible to find suspended and terminated certificates. In order to do so, select “terminated” or “suspended” in the
                                      category “Certificate Status” at info.fsc.org.
                                   58 (footnote 55)
                                   59 (footnote 55) § 14.1. This information shall be publicly available in the same languages as the public certification summaries
                                      published by the certification body.

                                                                                                                                      Guidelines for Stakeholders
31

Certification Bodies are obliged to have complaints and appeals procedures in place.60

Generally, the Certification Body shall provide an initial response within two (2) weeks after receiving
a complaint or appeal, including an outline of the certification body’s proposed course of action.
Within three (3) months after receiving the complaint or appeal the Certification Body shall have
investigated the allegations and specified all its proposed actions in response to the complaint and
shall keep the complainant(s) informed of the progress in evaluating the complaint or appeal.61

If the complainant is not satisfied with the outcome of the complaint evaluation by the Certification
Body on the complaint and has evidence that the complaint was not handled appropriately, he/she
can file a complaint to ASI (next level below).

Stakeholder – ASI
ASI is the second highest level in FSC’s dispute resolution.

At this point the stakeholder, the certificate holder and the CB have an understanding of compliance
with the national/regional FSC standard which is in heavy opposition to each other. If not already
done it is now overdue to contact the respective FSC National Office for advice and support!

ASI is responsible for the following types of complaints (Figure 5)
a) No satisfactory resolution could be found to the complaint and the appeal filed to the CB against
   the CH.
b) No satisfactory resolution could be found to the complaint and the appeal filed to the CB against
   the CB.
c) A complaint against ASI’s performance itself.

60 (footnote 55) § 6.1
61 (footnote 55) § 14.2.2

Guidelines for Stakeholders
32

                                   In these cases the stakeholder can file a complaint to ASI. ASI’s Compliance Manager or inves-
FSC COMPLAINTS MANAGEMENT SYSTEM

                                   tigator (appointed internally or externally) will then deal with the complaint.62 ASI’s decisions and
                                   measures taken to address a complaint cannot be appealed, but a new complaint can be filed to
                                   FSC if the complainant is not satisfied with the outcome of ASI’s complaint-handling process and
                                   has evidence that the complaint was not handled appropriately.63

                                   Violation of FSC’s Policy for Association
                                   FSC’s Policy for Association states that FSC will only allow its association (e.g. become FSC cer-
                                   tified, become a FSC member or FSC Network Partner) with organizations that are not directly or
                                   indirectly involved in the following unacceptable activities:

                                   a) Illegal logging or the trade in illegal wood or forest products;
                                   b) Violation of traditional and human rights in forestry operations;
                                   c) Destruction of high conservation values in forestry operations;
                                   d) Significant conversion of forests to plantations or non-forest use;
                                   e) Introduction of genetically modified organisms in forestry operations;
                                   f) Violation of any of the ILO Core Conventions.64

                                   Complaints against organizations associated with FSC about their compliance with FSC’s Policy for
                                   Association are dealt with by FSC. Decisions taken on Policy for Association complaints cannot be
                                   appealed. Decisions are taken by the FSC Board of Directors after evaluation by an independent
                                   Complaints Panel*.

                                   FSC
                                   Complaints against FSC are dealt with by FSC and processed according to the procedures outlined
                                   in Chapter 3.2.

                                   62 ASI-PRO-20-104 (V4-0) COMPLAINTS, § 6.2.2
                                   63 FSC-PRO-01-005 (V3-0) EN PROCESSING APPEALS, § 2.4
                                   64 FSC-POL-01-004 (V2-0) EN POLICY FOR THE ASSOCIATION OF ORGANIZATIONS WITH FSC, § 1

                                                                                                                  Guidelines for Stakeholders
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